Air/Water Quality meeting in Pinedale
Wyoming DEQ representatives give updates on progress since last meeting
by Pinedale Online!
August 9, 2008
On Monday, July 30, 2008, Wyoming Department of Environmental Quality (DEQ) Director, John Corra, and Air Quality Division (AQD) Administrator, Dave Finley, held a public meeting in Pinedale to update the community on progress with air and water quality concerns since the April town meeting.
Here are highlights of the updates DEQ discussed in the public meeting:
Increase of NOx & VOCs is no longer justifiable
DEQ’s has adopted a new policy that any increase in NOx/VOCs emissions in Sublette County in no longer justifiable or acceptable. The interim policy requires every application to demonstrate no new emissions or offset new emissions by removing/improving existing sources. Offsets must be approved, enforceable, and in Sublette County. Starting in August, applications must show at least 1.5 reduction in existing VOCs emissions for every 1 proposed increase, and NOx must be offset by 1.1 for every 1 proposed increase, resulting in a net reduction of emissions. NOx and VOCs combine in sunlight under the right conditions to create ozone. In Sublette County, ozone levels have been alarmingly high in recent years during February and March. Calm clear days with snow covering the ground appear to accelerate the formation.
Current data supports non-attainment status
Non-attainment is a federal Environmental Protection Agency (EPA) designation that is used to indicate a hazardous air condition that is required be corrected. Under a new standard defined in 2008, the acceptable level of ozone is 75 parts per billion (ppb) for three consecutive years, down from the previous standard of 84 ppb. The yearly number is calculated as the 4th highest 8-hour average in a given year. AQD is calculating the three consecutive years as an average instead of each of the three years having to be over the limit. This is significant since none of the monitoring stations in 2007 were above the limit of 75 ppb. However, the current yearly number for the Boulder monitoring station is 101 ppb for 2008 which would result in a three-year average (2006-2008) of 80 ppb, justifying a non-attainment designation.
DEQ is not prepared to issue a non-attainment designation partly because the 2008 number will not be official until the end of the year, but it can not go lower. DEQ is required to submit an attainment recommendation to EPA in March of 2009. The recommendation will be based on all available data at that time, but given the current data it is likely DEQ with recommend non-attainment in March 2009 for some if not all of Sublette County.
Non-attainment is an unacceptably long process
Dave Finley cautioned that non-attainment is not the silver bullet. The federally mandated process can take years to reach attainment. A typical scenario would take until 2016 to reach attainment. This is not acceptable to DEQ so, with cooperation from industry, they are moving ahead in parallel with non-attainment-like efforts to reduce NOx & VOCs immediately and not rely solely on the non-attainment process.
Reducing emissions
Finley reported that dehydration plants contribute about 57% of the total produced VOCs in Sublette County. Pneumatic pumps and tanks combine to produce another 31%. Drilling engines contribute about 50% of the total produced NOx. DEQ does permit and regulate dehydration plants and is developing new best available technology guidelines. But DEQ does not permit drilling rigs since they are mobile sources. EnCana and Anschutz have already voluntarily submitted application for their drill rigs. DEQ anticipates that the new Pinedale Anticline Project Area (PAPA) Record of Decision (ROD) will require drilling rig permits.
Finley reported that voluntary actions by industry have already reduced emissions of VOCs by 400 tons per year since April. AQD has issued a formal call for individual companies to commit to voluntary emission action and to develop contingency plans for short-term reductions of VOCs and NOx to be implemented during appropriate winter conditions. AQD will start forecasting in January and will issue alerts that will trigger contingency plans when appropriate conditions exist.
The new PAPA ROD is expected to require NOx to be reduced to 2005 levels within one year and a further 80% reduction beyond that within 42 months. In addition, industry is expected to provide additional monitoring funds which will include a new full-time inspector for the anticline.
Further Monitoring & Modeling
The Ambient Monitoring Network is currently under review to propose improvements in air monitoring. Plans are already in the works to place a new monitoring station in Pinedale. An independent ozone study of Sublette County will be conducted by Dr. Robert Field and Dr. Derek Montaque of the University of Wyoming. They will monitor and model 3D spatial distribution of ozone, measure incoming and outgoing ozone at the border of county, and refine emissions inventory. The study will solicit help from the public to wear monitors for personal exposure data.
Air Toxics Risk Assessment
In June, DEQ and Sublette County signed a Memorandum of Understanding (MOU) to conduct an air toxics risk assessment. The study will measure and determine the health risk of all toxins in the air in Sublette County including NOx, VOCs and ozone. The goals are to determine what toxins are we being exposed to, at what levels, and what is the health risk. An interim assessment will be available in December 2008, the complete toxicity will be available in December 2009, and the final report will be completed in August 2010.
Historical air quality monitoring data and charting for the Upper Green on the DEQ website.
By mid-August, DEQ expects to Beta test a database for their air quality monitoring stations which feeds the graphs on their website. Currently, data displayed only shows a "point in time" snapshot view. There is no way to retrieve historical data to see a timeline for the current day or previous days to understand conditions and changes over time. DEQ is working on making all data available, including historical data display and trends for their air quality and visibility monitoring stations. www.wyvisnet.com/
Ground Water Issues
Corra reported that there have been no new exceedances of ground water hydrocarbon standards since April. Concern arose when 1/3 of approximately 260 production wells showed hydrocarbons. (These are industrial wells tapping non-potable water sources, at deeper depths than drinking water aquifers.) One that exceeded health standards is in voluntary remediation. Five others in voluntary remediation had elevated high levels, but did not exceed standards. All others were low level and are just being monitored. Shell Rocky Mountain Production thinks hydrocarbon-based grease on the well pipes may have contaminated the water during drilling. Wells since drilled with a silicon grease have not shown any hydrocarbons. No hydrocarbons have been detected in stock or residential wells, so the contamination looks to be drilling related.
The PAPA ROD is expected to require aquifer characterization and a new monitoring plan. That will be funded by a $1.5 million from operators. This is in addition to other mitigation funds already proposed.
Audience Frustrations
Some vocal critics of the DEQ gave cautious praise for the presentation, but there was still an air of frustration. Many cannot understand how the BLM can sign the PAPA ROD for 4000 new wells before we understand and fix current problems. Hope is that non-attainment can somehow stop the ROD, but Corra and Finley made it clear that DEQ cannot control the issuing of drilling permits, nor do anything to stop the PAPA ROD. Instead they have worked with BLM to strengthen the ROD and are working with industry to reduce emissions.
There was concern for the many small sources that the AQD has no authority to regulate such as open reserve pits at drill sites and truck traffic.
Questions still remain:
- What does a 400-ton reduction, for example, really mean if total emissions are not known?
- The reductions are paper calculations. Will those translate to real reductions?
- How much reduction is needed for our air to be safe to breathe?
Next Meeting
Corra and Finley committed to keep coming back to Pinedale periodically to report progress. The next meeting will be in about three months. At that time they expect to have more information on the toxicity study and will talk more about the total emissions inventory for the county. The University of Wyoming study will also be defined and presented to the public.
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